The Clearing House Association (TCH) submitted a letter to the Financial Stability Oversight Council (FSOC) urging it to lead a coordinated effort of its member regulatory agencies to address and mitigate systemic risk arising from increasing market reliance on central counterparties (CCPs).  In the letter, TCH details a set of concrete recommendations that would subject CCPs to more stringent standards and help ensure that their risks are more carefully managed and mitigated. TCH recommends FSOC take five concrete steps: (i) Limited Mutualized Liability for Clearing Members: Regulators should ensure that the potential liability of non-defaulting members of a CCP in the event of a default by one or more other members is predictable, transparent, reasonable, and limited; (ii) Skin-in the-Game for CCPs: Regulators should insist that all CCPs have sufficient incentives to manage the risks arising from their operations (that is, have “skin-in-the-game”); (iii) Transparency, Stress Testing, and CCP Disclosure: Regulators should require greater transparency in CCP risk management practices, including methodologies for margin calculations, guaranty fund contributions, and the framework for stress testing and stress testing results; (iv) Safeguarding Collateral and Liquidity: Regulators should establish stronger safeguards for collateral posted by clearing members to the CCP, including standards for eligible collateral and consequent liquidity requirements, and (v) CCP Recovery and Resolution Planning: Regulators should develop effective standards and planning for the recovery and resolution of CCPs to ensure operational continuity.